EPA/ROD/R02-95/254
                                    1995
EPA Superfund
     Record of Decision:
     ANCHOR CHEMICALS
     EPA ID: NYD001485226
     OU01
     HICKSVILLE, NY
     09/29/1995

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                  DECLARATION FOR THE RECORD OF DECISION

SITE NAME AND LOCATION

Anchor Chemical Superfund Site

Town of Oyster Bay, Nassau County, New York


STATEMENT OF BASIS AND PURPOSE

This Record of Decision  (ROD) documents the U.S. Environmental Protection Agency's  (EPA's) selection of the
remedial action for the Anchor Chemical Superfund Site  (the "Site") in accordance with the requirements of
the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended  (CERCLA) , 42
U.S.C. §9601 et seq. and the National Oil and Hazardous Substances Pollution Continqency Plan  (NCP), 40 CFR
Part 300.  This decision document summarizes the factual and leqal basis for selectinq the remedy for the
Site.  An administrative record for the Site, established pursuant to the NCP, 40 CFR 300.800, contains the
documents that form the basis for EPA's selection of the remedial action, an index of which is appended to
this document  (see Appendix III).

The New York State Department of Environmental Conservation (NYSDEC) has been consulted on the planned
remedial action in accordance with CERCLA §121(f), 42 U.S.C. §9621(f), and it concurs with the selected no
further action remedy  (see Appendix IV).  A letter of concurrence from the NYSDEC is appended to this
document.

DESCRIPTION OF THE SELECTED REMEDY

EPA, in consultation with the State of New York, has determined that the Anchor Chemical Superfund Site does
not pose a siqnificant threat to human health or the environment and, therefore, further remediation is not
appropriate.  This determination is based on the findinqs of the Remedial Investiqation and the baseline Risk
Assessment.  The risks posed by the Site are within EPA's acceptable risk ranqe and therefore do not pose a
threat to human health or the environment.

Althouqh the risks posed by the Site contamination are within the acceptable risk ranqe, four dry wells on
Site are contaminated with chromium, lead, 1,1,1 trichloroethane (1,1,1-TCA) and other volatile compounds
(VOCs).   Groundwater samples from several monitorinq wells on Site also showed concentrations of chromium and
1,1,1-TCA, which were above MCLs.   The contaminated soils and sediments from the dry wells will be removed in
order to prevent further qroundwater contamination.  On September 15, 1995, K.B. Company, the owner of the
property, was issued a unilateral administrative order and Anchor Lith/Kem-Ko and Chessco Industries, a
former owner of Anchor Lith/Kem-Ko, were issued administrative consent orders by the EPA to remove the
contaminated sediment and soil from the four dry wells  (DWs),  desiqnated DW-2, DW-3, DW-6 and    DW-8, in
order to prevent further qroundwater contamination.  The excavated materials will be disposed of at a
Resource Conservation and Recovery Act (RCRA) approved facility.  Groundwater and soil samples will be
collected at the Site and analyzed to assess the effectiveness of the removal action.  Upon completion of the
removal action, EPA will take no further action at the Anchor Chemical Superfund Site.

DECLARATION OF STATUTORY DETERMINATIONS

In accordance with the requirements of CERCLA, as amended, and the NCP, EPA, in consultation with the State
of New York, has determined that the Anchor Chemical Superfund Site does not pose a siqnificant threat to
human health and the environment.   Therefore, no remedial action is necessary.

Because this remedy will not result in hazardous substances remaininq on-Site above health-based levels, the
five  (5) year review will not apply to this action.
        Jeanne M. Fox                                 Date
        Reqional Administrator

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SITE NAME, LOCATION AND DESCRIPTION

The Anchor Chemical Superfund Site is located at 500 West John Street in the Village of Hicksville, Town of
Oyster Bay, Nassau County, New York  (see Figure 1).   The surrounding area is predominantly industrial but
also has recreational areas.

The Site is bordered to the west by a commercial property, to the south by West John Street and to the
Northwest by Cantiague park, a 125 acre recreational facility.  A groundwater recharge basin lies to the east
of the Site.

The Site is approximately 1.5 acres in size and includes one 28,850 sguare foot, two-story building.  The
KoBar Company purchased the Site on September 30, 1964, and in the same year constructed the building for the
Anchor Chemical Company.  Before the building was constructed, the Site was used for agricultural purposes.

From 1964 to 1978, Anchor Chemical leased the Site from KoBar and began manufacturing, blending and storing
chemicals for the graphic arts industry.  The company operated two solvent mixing rooms and     several
container storage areas.  In 1964, seventeen (17) under-ground storage tanks (USTs),  which ranged in size
from 500 to 4,000 gallons, were installed under the mixing room for Anchor Chemical  (see Figure 2).  The
tanks were used to store chemicals and solvents, such as acetone, 1,1,1-trichloroethane, methylene chloride,
2-butoxyethanol and isopropyl alcohol.  The chemicals were also stored in seven aboveground tanks, which
ranged in size from 550 to 1,500 gallons.  The aboveground tanks were removed from the Site in 1985.

In addition, there are 9 dry wells and one drain, which are located in the parking lot on Site (see Figure
2).   The dry wells and drain were installed to collect rainwater run off and drainage from the building.
Most of the Site is paved with asphalt.  Liguid which collects in the dry wells infiltrates into the soil.
None of the dry wells are connected to a sewer.

SITE HISTORY AND ENFORCEMENT ACTIVITIES

In 1978, Anchor Chemicals was purchased by Chessco Industries and became known as Anchor/Lith Kem-Ko.
Company operations were terminated in 1985.  Since 1985, the following tenants have occupied the Site:  from
1985 to 1988, Emery Worldwide Freight, a shipping company; from 1988 to 1992, J. D. Brauner, a furniture
manufacturer; from 1992 to 1994, Distributors of America, a distributer of newspaper inserts; and from 1994
to present, Machinery Values, a machinery resale operation.

In 1977, the Nassau County Health Department (NCHD)  discovered 1,1,1-trichloroethane  (1,1,1-TCA),
trichloroethene (TCE) and tetrachloroethene (PCE) in liguid samples near drywell 1, which is located north of
the building in the parking lot (see Figure 2). In response, Anchor Chemical submitted a spill prevention
plan to the NCDH.

In May 1981, the Nassau County Fire Marshall notified Anchor/Lith Kem-Ko that the 17 USTs on Site had not
been registered with the Fire Marshall or tested for leaks.  In subseguent testing of 14 of the 17 USTs, 5
tanks failed air over product tank tightness tests.  The five tanks were decommissioned in 1983.  The three
remaining tanks, which were not tested in 1981, were tightness tested in 1982 and 1983, and one of these
tanks failed the test.  In 1982, the NCDH reguested Anchor/Lith Kem-Ko to investigate the possibility of
groundwater and soil contamination at the Site.

Three groundwater monitoring wells were installed in September 1982.  Groundwater samples taken from the
wells contained 24,000 parts per billion (ppb)  of 1,1,1-TCA, 1,100 ppb of PCE,  350 ppb of dichloroethane, 170
ppb of chlorodibromomethane, 41 ppb of methylene chloride and 55 ppb of TCE.  Soil samples, which were taken
during the installation of one well  (well number 1), revealed 490 ppb of methylene chloride and 22 ppb of
1,1,1-TCA.

In January 1983, the Site was included on the NYSDEC's list of hazardous waste sites in Nassau County.  On
June 10, 1986, the Site was added to the federal National Priorities List (NPL).

Subseguent monitoring of the Site by the PRP through 1991 has indicated a decrease in the concentration of

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contaminants in the groundwater.

On June 2, 1989, EPA issued an Administrative Order on Consent to the K.B. Company, the owner of the property
and successor to Kobar, to undertake a remedial investigation/feasibility study  (RI/FS) to   determine the
nature and extent of contamination at the Site and to evaluate options for cleanup.  On August 3, 1989, EPA
issued an Administrative Order to Chessco Industries, which reguired it to  participate and cooperate with
K.B. Company.  EPA issued an Administrative Order to Anchor Lith-Kem Ko. on March 31, 1992, which also
reguired it to participate and cooperate in the performance of the RI/FS.  RI field work was completed in
February 1995, and the RI report was compiled by the PRPs and submitted to the EPA in March 1995.  The Risk
Assessment was finalized by the EPA on June 2, 1995.

On September 15, 1995, K.B. Company, the owner of the property, Anchor Lith/Kem-Ko and Chessco Industries, a
former owner of Anchor Lith/Kem-Ko, were ordered by the EPA to remove the contaminated sediment and soil from
four on Site dry wells (DWs) designated DW-2, DW-3, DW-6 and DW-8.  K. B. Company was issued a unilateral
administrative order, while Anchor Lith/Kem-Ko and Chessco industries were issued an administrative consent
order for the removal work.  A workplan for the drywell removal action was approved by EPA on September 28,
1995.  The actual removal of the material from the drywells occurred on September 29, 1995.

HIGHLIGHTS OF COMMUNITY PARTICIPATION

On August 19, 1991, EPA held a public meeting at the Hicksville Library to inform the community of its intent
to oversee a remedial investigation of the Site.  At the meeting, EPA provided a brief summary of the Site
history, an overview of the federal Superfund process and summarized the RI work, which was to occur at the
Site.

The RI report, Risk Assessment report, and the Proposed Plan for the Site were released to the public for
comment on August 23, 1995.  These documents have been made available to the public in the administrative
record file at the EPA Docket Room in Region II, New York and the information repositories at the Hicksville
Library.  The notice of availability for the above-referenced documents was published in Newsday on August
23, 1995 and the Hicksville Illustrated News on August 25, 1995.  The public comment    period on these
documents was held from August 23, 1995, to September 21, 1995.

On September 12, 1995, EPA and the New York State Department of Environmental Conservation (NYSDEC)  conducted
a public meeting at the Hicksville Library to inform local officials and interested citizens about the
Superfund process, to review current and planned remedial activities at the Site, and to respond to any
guestions from area residents and other attendees.

Responses to the comments received at the public meeting and in writing during the public comment period are
included in the Responsiveness Summary  (see Appendix V).

SCOPE AND ROLE OF ACTION

This Record of Decision discusses EPA's selection of no further action for the Site.  Based on the findings
of the Remedial Investigation (RI) and EPA's baseline Risk Assessment, the risks at the Site are within the
EPA's acceptable risk range; therefore, the Site does not pose a threat to the public or the environment.

Four dry wells on Site are contaminated with chromium, lead, 1,1,1 trichloroethane  (1,1,1-TCA) and other
volatile compounds (VOCs).  Groundwater samples from several monitoring wells on Site also revealed
concentrations of chromium and 1,1,1-TCA which were above MCLs.  Contaminated soils and sediments from the
dry wells will be removed in order to prevent further groundwater contamination.  On September 15, 1995, K.B.
Company, the owner of the property, was issued an administrative order and Anchor Lith/Kem-Ko and Chessco
Industries, a former owner of Anchor Lith/Kem-Ko, were issued an administrative consent order by the EPA to
remove contaminated sediment and soil from four dry wells (DWs) designated DW-2, DW-3, DW-6 and DW-8.  A
workplan for the drywell removal action was approved by EPA on September 28, 1995.  The actual removal of the
material from the drywells is occurred on September 29, 1995. Excavated materials will be disposed of at a
Resource Conservation and Recovery Act  (RCRA) approved facility.  Groundwater samples     will be collected
at the Site and analyzed to assess the effectiveness of the removal action.

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SUMMARY OF SITE CHARACTERISTICS

The Remedial Investigation included:  1) inspection and closure of 12 USTs; 2) installation of four shallow
and four deep groundwater monitoring wells; 3) three rounds of groundwater samples; 4) two   rounds of soil
samples from under the USTs; and 5) one round of sediment samples from nine dry wells, one drain and two
cesspools.

Inspection and Closure of the Underground Storage Tanks

Figure 3 shows the arrangement of the tanks at the Site.  As mentioned above, five of the 17 USTs on-Site
(UST numbers 5, 6, 8, 11 and 15) were closed in 1983.  Tank closure was performed by filling the USTs with
concrete.  In June 1991, as part of the RI, the remaining 12 USTs were also filled with concrete.

Groundwater

Eleven on-Site monitoring wells were sampled in April and November 1992.  Two monitoring wells, MW-4 and
MW-5S, were re-sampled in February 1995.

All of the wells sampled are screened in the Upper Glacial Aquifer. Monitoring wells MW-4, 5S, 6S and 7S are
screened at 70 to 80 feet below land surface  (BLS); the deeper wells, MWs-lD, 5D, 6D and 7D, are screened 100
to 120 feet BLS.  Figure 3 shows the well locations.

The average depth to the water table at the Site is 50 to 60 feet. The following three water bearing geologic
units underlay the Site: the Upper Glacial Aquifer, the Magothy Aquifer and the Lloyd Aquifer.  The Upper
Glacial and Magothy Aquifers are hydraulically interconnected.  Water also flows from the Magothy to the
Lloyd Aquifer; however downward movement is extremely slow because of a thick confining clay known as the
Raritan Clay, which overlays the Lloyd Aquifer.  All three aquifers serve as a source of drinking water for
Long Island.

The direction of groundwater flow is to the southwest.  This was determined by the NCDH in 1986 and confirmed
during field testing in March and October 1992.  In 1985 a Site investigation report, produced by Lockwood,
Kessler and Barlett, a consultant hired by K.B. Company, the groundwater was reported to migrate at a rate of
approximately 0.45 feet per day.

Organic contaminants were detected in each of the three sample rounds.  1,1,1-TCA was detected in MW-3 (8
ppb, April 1992),  in MW-4 (3 ppb, November 1992) and in MW-5S  (29 ppb, February 1995). Bis(2-ethylhexyl)
phthalate was detected in MW-5S  (65 ppb, April 1992) and MW-7S (160 ppb, November 1992).  A number of
unspecified organic compounds also were detected in groundwater samples from each of the monitoring wells.

Inorganic contamination was found in higher concentrations.  Lead and chromium were detected in the
groundwater at levels which exceeded both federal and state maximum contaminant levels (MCLs) for drinking
water.  Samples taken in April 1992 revealed chromium at 317 ppb and 227 ppb in shallow wells MW-2 and MW-3,
respectively, and 132 ppb in deep well MW-1D.  The November sample round revealed chromium at 1440 ppb in
well MW-2 and 1150 ppb in well MW-3.

Lead was detected in shallow wells MW-2 and MW-3 at 74.7 ppb and 30.2 ppb, respectively, for the first round
and 240 ppb and 71.5 ppb, respectively, for the second round.  MW-5D revealed lead at 31.4 ppb and 40.4 ppb
for the first and second rounds.

EPA and New York State MCL and action level concentrations exist for lead, chromium, 1,1,1-TCA and the total
concentration of unspecified organic compounds.  Water which has concentrations of lead, chromium and
unspecified organic compounds which exceed MCL concentrations may not be safe for consumption.  New York
State MCLs for the contaminants detected in the groundwater are as follows:  chromium - 50 ppb, 1,1,1-TCA - 5
ppb, bis(2-ethylhexyl)-phthalate - 50 ppb, and the total concentration of unspecified        organic
compounds - 100 ppb.  The federal EPA MCLs are 200 ppb for 1,1,1-TCA and 100 ppb for chromium.  No federal
MCL has been established for unspecified organic compounds.  For lead, EPA has established an action level of
15 ppb.

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EPA believes that the elevated levels of lead, chromium, 1,1,1-TCA and unspecified organic compounds, which
were detected in the groundwater, will decrease once the sediments from drywells 2, 3, 6, and 8 are removed.
As indicated below, analysis of samples collected from sediments in these dry wells revealed high levels of
lead and chromium.

Soil and Sediments

Minimal concentrations of organic chemical contamination were detected in the soil samples that were obtained
from below the underground storage tanks.

Elevated levels of the following contaminants, however, were found in the sediment sample from DW 2:  1,1-DCA
(1,600 ppb), 1,1,1-TCA (3,300 ppb),  toluene  (4,800 ppb), xylene  (67,000 ppb) and bis(2-      ethylhexyl)
phthalate  (27,000 ppb).  Chromium (Cr) and lead (Pb) contamination were also detected in the sediment samples
from DWs 2, 3, 6 and 8 at the following levels:  DW 2 - Cr 463 ppm, Pb - 1,210 ppm; DW 3 - Cr 101 ppm, Pb 607
ppm; DW 6 - Cr 240 ppm, Pb 1,120 ppm; and, DW 8 - Cr 198 ppm, Pb 1,620 ppm.  Finally,  various unspecified
organic compounds were detected in the sediments.   The following levels (total concentrations)  were detected:
DW 2- 1,302.5 ppm, DW 3 - 226.2 ppm, DW 6 - 26 ppm and DW 8 - 85.3 ppm.

Removal of soil and sediments from these dry wells should reduce the concentrations of chromium, lead,
1,1,1-TCA, bis(2-ethylhexyl)phthalate, and the total concentration of unspecified organic compounds in the
groundwater.  Soil and groundwater samples will be collected to confirm the effectiveness of the removal
action.

Sediment samples from dry wells 1, 4, 5, 7 and 9 and the drain revealed levels which ranged from 81.3 ppm to
216 ppm for lead and 17.4 ppm to 71 ppm for chromium.  These levels are not considered high enough by the EPA
and the NYSDEC to have an adverse impact on the groundwater.  Therefore, no excavation of the sediments from
these dry wells or the drain will be reguired.

Finally, two cesspools (see Figure 2), which were abandoned in 1982, were sampled.  One soil sample was
collected from each cesspool.  Trace levels of methylene chloride and two pesticides,  dieldrin and
methoxychlor, were detected.

SUMMARY OF SITE RISKS

Based upon the results of the RI, a baseline risk assessment was conducted to estimate the risks associated
with current and future Site conditions.  The baseline risk assessment estimates the human      health and
ecological risk which could result from the contamination at the Site if no remedial action were taken.

Human Health Risk Assessment

A four-step process is utilized for assessing site-related human health risks for a reasonable maximum
exposure scenario.  Hazard Identification—identifies the contaminants of concern at a site based on several
factors such as toxicity, freguency of occurrence, and concentration.  Exposure Assessment—estimates the
magnitude of actual and/or potential human exposures, the freguency and duration of these exposures, and the
pathways  (e.g.,  ingesting contaminated well-water) by which humans are potentially exposed.  Toxicity
Assessment—determines the types of adverse health effects associated with chemical exposures,  and the
relationship between magnitude of exposure (dose)  and severity of adverse effects  (response).  Risk
Characterization—summarizes and combines outputs of the exposure and toxicity assessments to provide a
guantitative assessment of site-related risks.

EPA conducted a baseline risk assessment to evaluate the potential risks to human health and the environment
associated with the Site in its current state.  The Risk Assessment focused on contaminants   in the soil and
groundwater which are likely to pose significant risks to human health and the environment.  A summary of the
contaminants of concern in the matrices sampled is provided in Table A.

EPA's baseline risk assessment addresses the potential risks to human health by identifying several potential
exposure pathways by which the public may be exposed to contaminant releases at the Site under current and

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future land-use conditions.  However, groundwater and soil exposures were only assessed for a future land use
scenario.  Groundwater at the Site is not currently used for consumption, so an evaluation of a present
exposure scenario is not necessary.  In addition, although risks were calculated for future  residential
development, the Site is zoned for light industry and is not expected to change.

The exposure pathways considered under future uses are listed in Table B.  A total of four exposure pathways
were guantitatively evaluated under possible on-Site future land-use conditions: ingestion of groundwater,
inhalation of groundwater contaminants, incidental ingestion of soil, and dermal contact with soils.  The
reasonable maximum exposure for each pathway was evaluated.  Two other exposure pathways were evaluated
gualitatively:  dermal contact with groundwater and inhalation of VOC emissions and soil     particulates.
Both pathways were expected to be less significant because of the short duration of exposures.

Under current EPA guidelines, the likelihood of carcinogenic (cancer-causing) and noncarcinogenic effects as
a result of exposure to site chemicals, are considered separately.  It was assumed that the toxic effects of
the Site-related chemicals would be additive.  Thus, carcinogenic and noncarcinogenic risks    associated
with exposures to individual compounds of concern were summed to indicate the potential risks associated with
mixtures of potential carcinogens and noncarcinogens, respectively.

Noncarcinogenic risks were assessed using a hazard index (HI)  approach, based on a comparison of expected
contaminant intakes and safe levels of intake (Reference Doses, of RfDs).  RfDs have been developed by EPA
for indicating the potential for adverse health effects.  RfDs, which are expressed in units of
milligrams/kilogram-day (mg/kg-day),  are estimates of daily exposure levels for humans which are thought to
be safe over a lifetime (including sensitive individuals).   Estimated intakes of chemicals from
environmental media (e.g., the amount of a chemical ingested from contaminated drinking water) are compared
to the RfD to derive the hazard guotient for the contaminant in the particular medium.  The HI is obtained by
adding the hazard guotients for all compounds across all media that impact a particular receptor population.

An HI greater than 1.0 indicates that the potential exists for noncarcinogenic health effects to occur as a
result of site-related exposures.  The HI provides a useful reference point for gauging the potential
significance of multiple contaminant exposures within a single medium or across media.  The reference doses
for the compounds of concern at the Site are presented in Table C.  A summary of the noncarcinogenic risks
associated with these chemicals across various exposure pathways is found in Table D.

The results of the risk evaluation for the Site indicated a non-cancer risk for the ingestion of groundwater
exposure scenario for future residents to be a Hazard Index (HI) of 3  (see Table d).   The HI resulted from
the presence of four metals:  aluminum (HQ of 0.8), arsenic (HQ of 0.3),  iron (HQ of 0.8) and manganese  (HQ
of 0.8). However, each of these metals affects a different target organ.  Because the toxicologic effects of
the metals are non additive, i.e. their toxic endpoints are different, the actual risk for the Site is
probably less than an HI of 3.  The HI for ingestion or dermal contact with subsurface soils by excavation
workers is less than one.

Potential carcinogenic risks were evaluated using the cancer slope factors developed by EPA for the
contaminants of concern.  Cancer slope factors (SFs) have been developed by EPA's Carcinogenic Risk
Assessment Verification Endeavor for estimating excess lifetime cancer risks associated with exposure to
potentially carcinogenic chemicals.  SFs, which are expressed in units of (mg/kg-day)-1, are multiplied by
the estimated intake of a potential carcinogen,  in mg/kg-day,  to generate an upper-bound estimate of the
excess lifetime cancer risk associated with exposure to the compound at that intake level.  The term "upper
bound" reflects the conservative estimate of the risks calculated from the SF.  Use of this        approach
makes the underestimation of the risk highly unlikely.

The SF for the compounds of concern are presented in Table C.   A
        summary of the carcinogenic risks associated with these chemicals
        across various exposure pathways is found in Table E.

The carcinogenic risk associated with a future Site resident ingesting groundwater was estimated to be 8 x
10-5, which represents a probability of 8 people in 100,000 developing cancer as a result of consuming 2
liters of untreated groundwater from the Site for 350 days per year for 30 years.  The carcinogenic risk for

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excavation workers ingesting subsurface soils and sediments was estimated to be 3 x 10-7.  EPA's acceptable
cancer risk range is 10-4 to 10-6.  This represents a one-in-ten-thousand to one-in-a-million   increased
probability that an individual will develop cancer under the Site specific exposure conditions over a
lifetime.

The risk evaluation for the Site indicates that the human health risks associated with the Site are within
EPA's acceptable risk range.  However, removal of the contaminated soil and sediments from dry wells 2, 3, 6
and 8 should further reduce the potential for future risks as a result of groundwater ingestion by future
Site residents because elevated levels of aluminum, lead, arsenic and manganese were detected in the dry
wells and are a probable source of contamination to the groundwater.  Reducing or eliminating
contamination to the groundwater, will also protect the Upper Glacial and the lower Magothy aguifer which
serves as a sole source drinking water aguifer for Long Island.  Finally, although lead and chromium did not
contribute to the calculated risks, they were also detected at elevated concentrations in the sediments of
the four dry wells and in groundwater samples above drinking water standards from monitoring wells MW-2, 3
and 5S.

Ecological Risk Assessment

A four-step process is utilized for assessing site-related ecological risks for a reasonable maximum exposure
scenario: Problem Formulation--a gualitative evaluation of contaminant release, migration, and fate;
identification of contaminants of concern, receptors, exposure pathways, and known ecological effects of the
contaminants; and selection of endpoints for further study. Exposure Assessment—a guantitative evaluation of
contaminant release, migration, and fate; characterization of exposure pathways and receptors; and
measurement or estimation of exposure point concentrations.  Ecological Effects Assessment—literature
reviews, field studies, and toxicity tests, linking contaminant concentrations to effects on ecological
receptors.  Risk Characterization—measurement or estimation of both current and future adverse effects.

The Site is located in a primarily urban industrialized area. Except for a narrow strip of lawn and
plantings, the Site is entirely covered by the existing building or asphalt.  There are no significant
habitats present at the Site which could potentially support indigenous wildlife receptor species.  The Site
may however provide a habitat for various non-native species which have adapted to highly urbanized areas
(e.g. rats, starlings and pigeons).

Aguatic habitats or wetlands are not present within the vicinity of the Site.  Although ecologically
significant areas are not known to be located in the vicinity of the Site, potential habitats include
cemeteries, school grounds, and Cantiague Park.  The 125 acre Cantiague Park includes a golf course and is
likely to provide for a variety of wildlife species.  However, because of the extensive development and lack
of suitable vegetated habitats at the Site, potential receptor species which may inhabit the adjacent
Cantiague Park (e.g. various songbirds and small animals) are not expected to freguent the Site.  Therefore,
the Site poses no ecological risk.

Uncertainties

The procedures and inputs used to assess risks in this evaluation, as in all such assessments, are subject to
a wide variety of  uncertainties.  In general, the main sources of uncertainty include:

         !    environmental  chemistry  sampling  and  analysis
         !    environmental  parameter measurement
         !    fate and  transport modeling
         !    exposure  parameter estimation
         !    toxicological  data

Uncertainty in environmental sampling arises in part from the potentially uneven distribution of chemicals in
the media sampled. Conseguently,  there is significant uncertainty as to the actual levels present.
Environmental chemistry analysis error can stem from several sources including the errors inherent in the
analytical methods and characteristics of the matrix being sampled.

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Uncertainties in the exposure assessment are related to estimates of how often an individual would actually
come in contact with the chemicals of concern, in the period of time over which such exposure would occur,
and in the models used to estimate the concentrations of the chemicals of concern at the point of exposure.

Uncertainties in toxicological data occur in extrapolating both from animals to humans and from high to low
doses of exposure, as well as from the difficulties in assessing the toxicity of a mixture of chemicals.
These uncertainties are addressed by making conservative assumptions concerning risk and exposure parameters
throughout the assessment.  As a result, the Risk Assessment provides upper-bound estimates of the risks to
populations near the Site, and it is highly unlikely to underestimate actual risks related to the Site.

Future land use and future use of public drinking water supplies are difficult to define.  For this action,
local zoning officials and Site documents including the RI report were consulted for information.  Risk
scenarios are based on land use and water supply estimates that would result in "reasonable maximum"
exposures.  The groundwater ingestion scenario may overestimate risk because it assumes that 1)  private wells
will be installed on or adjacent to the Site and will draw water from contaminated areas, or 2)
contaminant concentrations detected in the on-Site monitoring wells will reach private residential wells.

More specific information concerning public health risks,  including a guantitative evaluation of the degree
of risk associated with various exposure pathways, is presented in the Risk Assessment Report.

STATE ACCEPTANCE

The State of New York concurs with EPA' s selected no further action alternative pending successful completion
of the drywell removal action.  Their letter of concurrence is attached as Appendix IV.

COMMUNITY ACCEPTANCE

Community acceptance of the preferred remedy has been assessed in the Responsiveness Summary portion of this
ROD, following review of all public comments received on the RI report and the Proposed Plan.  All comments
submitted during the public comment period were evaluated and are addressed in the attached Responsiveness
Summary.

Comments on EPA' s Proposed Plan for the Site were received from the public and the Nassau County Department
of Health (DOH).  The public commented on the following issues:  the source of Site contaminants, Site
related cancer incidence, the drywell removal action and deed restrictions for a future sale of the Site
property.  No specific objections were raised by the public on implementation of the Site remedy, i.e.
removal of contaminated soil and sediments from four dry wells and no further action.  The Nassau County DOH
did not, however, think that the remedy was adeguate and recommended that off Site groundwater monitoring be
conducted in addition to the removal action.

EPA's specific responses to the comments concerning the Anchor Chemical Superfund Site Proposed Plan can be
found in Appendix V.

SEIiECTED REMEDY

EPA has determined after reviewing the alternatives and public comments that no further action beyond the
successful completion of the drywell removal action is the appropriate remedy for the Site because it best
satisfies the reguirements of CERCLA §121, 42 U.S.C. §9621, and the NCP's nine evaluation criteria for
remedial alternatives, 40 CFR §300.430(e) (9).

An evaluation of all available data, the findings of the RI conducted at the Site, EPA's Risk Assessment, and
other supporting data and documentation indicate that the Site risks are within EPA's acceptable risk range
and that a no further action decision is protective of human health and the environment.

In addition, although groundwater sampling results indicate some occurrence of contaminants exceeding MCLs,
the distribution of the contaminants indicated either off Site sources or localized contamination.
Furthermore, the removal action conducted by the PRPs will remove any potential source of contamination to

-------
the groundwater.   EPA believes that elevated levels of lead chromium, 1,1,1-TCA and unspecified organic
compounds which were detected in the groundwater will decrease once the sediments from drywells 2, 3, 6 and
are removed.

DOCUMENTATION OF SIGNIFICANT CHANGES

There are no significant changes from the preferred alternative presented in the Proposed Plan.

-------
                                    APPENDIX I

                                      FIGURES




-------
                          APIENDIX II

                             TABIiES
                                         TABLE A:
        CONTAMINANTS OF CONCERN, FREQUENCY OF DETECTION, RANGE OF CONCEN-
           TRATIONS DETECTED, 95% UPPER CONFIDENCE LEVEL CONCENTRATION
                       VALUES USED IN THE RISK ASSESSMENT

     SUMMARY STATISTICS FOR THE ANCHOR CHEMICAL SITE
                       UNITS:
ing/Kg.




Arithmetic

Mean
                                         SUMMARY STATISTICS FOR THE ANCHOR CHEMI
                               all water analyses are ug/L, organic soils are ug
                     95 Pet.
               Upp. Conf.
       Class         Analyte
        Limit       Det.Limit
      Num.
    Lowest
      Times
Observed

   Det.Limit
TYPE=Ground Water

                 Lowest       Hi

                Detected     Det

            Analyzed        Cone
     Num.
     Highest
    Samples
  Observed
Detected
       VOCs
4.13
               5.00
                     1,1,1-Trichloroethane
                               10.00
                       6

                      22
                     22

                  2.00
                                                       22
                                                                           3.00

                                                                              2.
               1,1-Dichloroethane          1           22         2.00        2.
               1,2-Dichloroethene  (tot)           1            22            3.0
               Acetone                     1      22       150.00      150.00
               Chloromethane               1      22         2.00        2.00
MW-1S-II         4.86           5.27         10.00           10.00
       BNAs         4-Methylphenol              1            22
5.82        6.52          10.00
               Butylbenzylphthaiate
MW-1D-II         4.75           7.13
               Chrysene
               Di-n-octylphthalate
               Diethylphthalate
               Fluoranthene
MW-7D-II         5.73           7.01
               Pyrene                      3         22           1.00        3.
               bis(2-Ethylhexyl)phthalate      13      22         5.00       160
MW-7S-II          28.48        53.84         10.00            20.00
            10.00
               1
        50.00
               7
            10.00
            22
          2         21
          3      22
          1      22
            10.00
                                                                  1.00
                                                             50.00
                                                        1.00         1.00      M
                                                                  1.00        3.
                                                             1.00        2.00
                                                             1.00        1.00
                                                             50.00

-------
Pest/PCBs Heptachlor epoxide
MW-1S-II
0.03
0.03
Inorganics Aluminum

2.37

MW-2-II



MW-2-II

5.31

67.98

MW-2-II



151.15


MW-1S-II

5798.07

MW-2-II

MW-2-II

Arsenic
3.09 2.
Barium
57.94 138.00
Cadmium
Calcium
Chromium
204.10 496.06
Cobalt
0.91 2.00
Copper
126.23
Iron
6480.34 14695
Lead
Magnesium
Manganese

Mercury
Nickel
30.46 61.22
Potassium
7523.74
Sodium
18529.55 34908
Vanadium
10.48 24.75
Zinc

00




22




17.
22
.15
19
22





19


.10
6

18

17
3
10
20
3.
1
22

.
3
14.00

00
22
.
19
22


5
17
7.

1690.00
22
.
22
1.
19
1 22 0.08
0.05 0.
22 314.00
22
.00
22 7.00
00 19.20
22 4.00
22 5880.00
22 11.00
.
0.
00
53100
6.40 9.

230.

4.00
50500.00
1440.

22 10.50

17 22
27.00
458.00 40900

10.20 240.
550.00 3070
22 22

22
22 8.20
90 10.00
22 1010.00
1960.00
22 2090.00

6.00 72.
00 6.00
45.00 342.

26.00

.00

00 M
.00 M
8.2

0.06
97.40

61500.

52500.0

40

00 M

-------
SUMMARY STATISTICS FOR THE ANCHOR CHEMICAL SITE    (CONTINUED).

                                    SUMMARY STATISTICS  FOR  THE ANCHOR CHEMI
                  UNITS:  all water analyses are ug/L,  organic soils  are  ug  ing/Kg.

                                   TYPE=MW-6S MW-6D/Ground  Water

Arithmetic
Mean
Class
Limit
BNAs
4.00
21.34
Num.
95 Pet. Lowest
Times
Upp. Conf. Observed
Analyte
Det. Limit Det. Limit
Butylbenzylphthalate
Di-n-octylphthalate
57.96 10.00
bis (2-Ethylhexyl)phthalate
10.00 28.00
Inorganics Aluminum 2
Barium 4
MW-6S-II


MW-6S-II

MW-6S-II

MW-6D




79.73
40.70 2959.42
Calcium 4
Chromium
36.50 200.84
Copper 2
Iron 4
792.25 2025.63
Lead 2
Magnesium 4
Manganese
53.58 270.84
Nickel 2
Potassium 4
Sodium
Zinc
354.88
Num. Lowest Hi
Highest
Samples Detected Det
Observed
Detected Analyzed Cone
2 4 1.00
1 4 1.00
10.00
2 4 5.0
4 353.00 803.00
4 7.00 75.70
.
4 12400.00 24200.
4 4 13.00
.
4 33.00 79.80
4 458.00 1370.0
.
2 25.20 29.40 M
4 1670.00 2760.00 M
4 4 20.90
4 20.90
4 2270.00 5010.00 M
4 4 10600.00 1
3 3 48.00


-------
     SUMMARY STATISTICS FOR THE ANCHOR CHEMICAL SITE    (CONTINUED).
                       UNITS:
ing/Kg.




Arithmetic

Mean
                     SUMMARY STATISTICS FOR THE ANCHOR CHEMI
           all water analyses are ug/L, organic soils are ug
 95 Pet.
               Upp.  Conf.
       Class         Analyte
        Limit       Det.Limit
      Num.
    Lowest
      Times
Observed

   Det.Limit
     TYPE=Sediments

     Num.         Lowest       Hi
     Highest
    Samples      Detected     Det
  Observed
Detected     Analyzed        Cone
       VOCs
1,1,1-Trichloroethane
               1,1-Dichloroethane          1
               Carbon Disulfide            2
167.20          13739.66       5.50
               Ethylbenzene                1
540.30          205239.90           5.50
               Toluene                     4
               Total Xylenes               1
       BNAs         2-Methylnaphthalene
          1381.98          2994.05        339.90
               Benzo(a)pyrene              2
               Benzo(b)fluoranthene
1236.91            2480.21         339.90
               Benzo(k)fluoranthene
    1092.91            2106.12         339.90
               Benzoic Acid                1
       5412.90           65294.75        8720.00
               Butylbenzylphthaiate
1676.77           13698.72          1798.50
               Chrysene               4
  956.87            2578.16         339.90
               Di-n-butylphthalate         3
1185.15          4062.60       1798.50
               Fluoranthene                4
               Indeno(1,2,3-cd)pyrene
1131.92          2101.22        339.90
               Naphthalene                 1
               Phenanthrene
769.94           2068.05        339.90
                                  10          3
                         1600.00     1600.00
                                     5.00
                                               4800.00 4800.

                                                  4800.00
                                                  67000.00
                                                3900.00
     10
        10
2100.00
        10
   1150.00
     10       5.00
     10   67000.00
 1           10
          2999.70
     10           580.00    1100.
    2          10          1000.0
    2999.70
          10           560.00
        2999.70
     10      73.00       73.00
          14544.00
 6        10      40.00      5200
     2999.70
10     230.00      2000.00     DW
     2999.70
        10            72.00 2500.
2999.70
     10     410.00     3400.00
 1           10          1500.00
2999.70
     10    9500.00     9500.00
   5           10           190.0
2999.70

-------
9610.00
DW-4
29.00

Pyrene

5
bis (2-Ethylhexyl)phthalate
I
60724.00
1000.00
Pest/PCBs 4, 4 '-DDE





22,



Dieldrin
Endrin
Methoxychlor
35.66
alpha-BHC
.47 106.
beta-BHC
gamma-chlordane
DW-8 22.58
6


81.56

43 3
1

10
3


34

.00
10

4500.
00
21000.

0
12000.00
6

2
7


.44

2
9
9
9
9
34
1

9

46.84
Inorganics Aluminum


















Antimony
Arsenic
Barium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Sodium
Thallium
Vanadium
Zinc
3



10


10
10
10
10


10

2
10
10
10
10
9
10
10
10
8
10
10
10
10
10
2
10
10
6
10

10
10

10
10
10





.40

6

9
34.

9.



17.
10
16
12
7
.00
.00
.00
.50




146.
106.
36.
126
00
00
00
.00




38.40
9
.00
8

40
1410
50
0
9
1300
40
183.00

.20



3.40

8.


20




68.00
.00

.79
.70
.00

10
10

3810.



9
10
81.
950.
51.


5
00
30
00
45
0
4
.30




.26
.70

12.



463.
3.10

22700
1620.
14100
189.


186.00


10

6
0.

24.
11100
00
3.
90.
22900
00

266.
.00
00
.00
00
0.
21.
615.
447.00
20
5
60

.38

0.

1770.
33
81.
00
.00

70
20
.00

11
00




34
50
00
1240

00


D



D
.

D
D
D
D



.
D

D

-------
     SUMMARY STATISTICS FOR THE ANCHOR CHEMICAL SITE   (CONTINUED).
ing/Kg.
  Mean
       Class
          Limit
                                         SUMMARY STATISTICS FOR THE ANCHOR CHEMI
                       UNITS:  all water analyses are ug/L, organic soils are ug
  Upp. Conf.
      Analyte
       Det.Limit
                                                    TYPE=Deep Subsurface Soils
      Num.
      Times
  Observed

     Det.Limit
          Num.          Lowest
         Samples      Detected
         Observed
     Detected     Analyzed
                               Hi Arithmetic
                              Det

                             Cone
                                                                                                   95 Pet.
                                                                                                                   Lowest
                                                                                                                   Highest
       VOCs
MW-7D(56-58')
       BNAs
IB-6(40-42')
       Pest/PCBs
MW-7D(114-116)
       Inorganics
IB-3(30-34')
     2-Butanone
      0.70
                       10.77
     bis(2-Ethylhexyl)phthalate
IB-3(35-39')

IB-1(15-17')

MW-7D(56-58')


IB-3(35-39')

MW-6D(60-62')

124.79



IB-3(30-34')

MW-5D(115-117)
    106.77
     Heptachlor
      4.49
     Aluminum
    888.35
Arsenic
Barium
Cadmium
 0.48
Calcium
31.06
Chromium
 4.19
Cobalt
Iron
   3114.26
Lead
 1.00
Magnesium
  379.05
Manganese
Nickel
Potassium
    156.21
Selenium
 0.36
Sodium
    253.53

      7.46
         20
   1150.63
         16
     10.00

    330.00
      1
      8.00
 0.58

44.94
    14
 5.61
11
 4
 0.40
 1
21.50

 2.90
 2
     20

     20
     19
     20

     14
               20      32.00
                21.00
               20      36.00
               693.00
          20       0.20
                16.00
            290.00     2130.00
                        0.
20
                   20
    19        19
   4574.32
    13        17
 1.27     0.83
    16        16
       0.24
       0.82
       0.59
     1.40
     160.00
    74.00
  1.40
     4.50
       1.50
655.00

  0.62
     1.20
  7.50
    20
              20
        1.90
       12.30
        0.92

      160.00

  23.20

        1.60
9140.00

   2.10

 473.00

  93.30
                       7.20
          1        19       1.50        1.50
     3        20      91.50      220.00
    245.63    58.00          420.00
     1        20       0.76        0.76
 0.42     0.40            0.88
          2        10     164.00      201.00

-------
MW-7D(56-58')      186.17            517.23    14.00          890.00
               Vanadium               8        20       1.40        6.10       I
               Zinc                   7        13       3.10       12.90       I

-------
                                        TABIiE B:

                              EXPOSURE PATHWAYS CONSIDERED

                       ANCHOR CHEMICAL SITE:  SUMMARY OF EXPOSURE PATHWAYS

                                                                     TIME-FRAME
                                                                     EVALUATED

     Pathway                         Receptor           Present         Future
Qual.          Rationale for Selection or Exclusion              Data Grouping

     Ground Water

     Ingestion of Ground Water            Resident          No             Yes
     Inhalation of Ground Water           Resident           No              Yes
     Contaminants during Showers

     Inhalation of Contaminants that           Resident           No
to ground water, 60 feet, precludes
     Volatilize from Ground Water and Seep
     into Basements

     Dermal Contact with Ground Water     Resident           No              Yes
     Soils and Sediments

     Incidental Ingestion of Soils        Excavation Worker  No       Yes      X




     Dermal Contact with Soils*           Excavation Worker  No              Yes
     Inhalation of VOC Emissions and           Excavation Worker  No
     Particulates from Soils

       *Cadmium, PCB, and dioxin only (if present).

-------
                                    TABLE C:

                   ORAL CHRONIC AND SUBCHRONIC TOXICITY VALUES

                  TOXICITY VALUES FOR CONTAMINANTS OF CONCERN AT THE
                 ANCHOR CHEMICAL SITE

                                   CARCINOGENIC
Chemical
Weight
of Evidence
Classification
          Volatiles
Carbon disulfide
1,1-Dichloroethane            C    a
Ethylbenzene                  D    a
Toluene                       D    a
1,1,1-Trichloroethane         D    a
Xylenes                       D    a
                BNAs
Benzoic acid                  D    a
Benzo(a)pyrene               B2    a
Benzo(b)fluoranthene         B2    a
Benzo(k)fluoranthene         B2    a
Benzylbutylphthalate          C    a
Bis(2-ethylhexyl)phthalate   B2    a
4-Chioroniline
Chrysene                     B2    a
Diethylphthalate              D    a
Di-n-butyl phthalate          D    a
Di-n-octyl phthalate
Fluoranthene                  D    a
Indeno(1,2,3-cd)pyrene       B2    a
2-Methylnaphthalene
Naphthalene                   D    a
Phenanthrene                  D    a
Pyrene                        D    a
          Pesticides
alpha-BHC                    B2    a
beta-BHC                      C    a
gamma-Chlordane (r)          B2    a
4,4' DDE                     B2    a
Dieldrin                     B2    a
Endrin                        D    a
Methoxyclor                   D    a
Oral Slope
Factor
(mg/kg/day)-1
                      7.30E-01 d
                      6.30E+00 a
                      1.80E+00 a
                      1.30E+00 a
                      3.40E-01 a
                      1.60E+01 a
Chronic
Oral RfD
(mg/kg/day)
                                            l.OOE-
                                            l.OOE-01 ab
                                            2.00E-01 ab
                                            9.00E-
                                            2.00E+00 a 4.00E+00 b

                                            4.00E+00 a 4.00E+00 b
                                              7.30E+00 a
                                              7.30E-01 d
                                              7.30E-01 d
                                           2.00E-01 2.00E+00 b
                                             1.40E-02 a
                                            4.00E-03
                                              7.30E-02 d
                                           8.00E-0
                                           1.00 l.OOE+00 b
                                         2.00E-02 b 2.00E-02 b
                                           4.00E-0
                                              3.00E-02
                         6.00E-05 6.00E-05 b

                         5.00E-05 a
                       3.00E-04 a 3.00E-04 b
                       5.00E-03 a 5.00E-03 b

-------
          Inorganics
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium, total
Cobalt
Copper
Iron
Lead
Manganese
Mercury
Nickel
Thallium
Vanadium
Zinc
 D

 A

B2
Bl
 D
 D
B2
 D
 D
 A
                              D
a
a
a
c
a
a
a
a
          2.00E+00 f

       4.30E+00 a
     l.OOE+00 c l.OOE+00 e
       4.00E-04 a 4.00E-04 b
     3.00E-04 3.00E-04 b
      7.00E-02 a 7.00E-02 b
      5.00E-03 a 5.00E-03 b
      5.00E-04 a,g
      8.76E-01 8.77E-01 h

     5.50E-02 c 5.50E-02 e
     5.00E-01 c 5.00E-01 e

     5.00E-03 a,i l.OOE-01 b
     3.00E-04 b
     2.00E-02 a,j 2.00E-02 b
7.00E-05 b,k 7.00E-04 b,k
7.00E-03 b 7.00E-03 b
     3.00E-01 b 3.00E-01 b
a.  From IRIS.
b.  From HEAST.
c.  Interim values from BCAO.
d.  Oral slope factor for B(a)P used for PAHs classified as B2 carcinogens
e.  Chronic RfD used as Subchronic RfD if no Subchronic values is available
f.  Arsenic oral slope factor derived from unit risk in IRIS.
g.  Cadmium RfD is for water, l.OE-03 mg/kg/day is RfD for food.
h.  Value is weighted-average value of the Hex and Tri RfDs assuming 7 part
i.  Manganese RfD is for water, RfD for food is 1.4E-1 mg/kg/day.
j.  Value is for nickel, soluble sales.
k.  Value is for

-------
                                    TABLE D:

         NONCARCINOGENIC RISK ESTIMATES FOR EACH EXPOSURE PATHWAY AND
                             RECEPTOR ASSESSED.

                    SUMMARY OF NONCARCINOGENIC HAZARD INDICES  (HI)
                    ESTIMATED FOR THE ANCHOR CHEMICAL SITE
Scenario

Ground Water

Ingestion


Inhalation
      Receptor
Onsite and/or
Adjacent Resident

      Onsite and/or
Adjacent Resident
Present/Future
                                              Chronic H
              3 x 10+0*
                                                                2x1
                                                            3 x 10+0*
Subsurface Soil and Sediments
Ingestion
Dermal Contact
Excavation Worker          F
     Excavation Worker     F
              4 x 10-lb
              4 x 10-4b
              4 x 10-1
a Chemical-specific risk assessment summary information is presented in the
b HI is based on Subchronic Protective Body Dose.
^Exceeds unity.

-------
                                    TABLE E:

                          CARCINOGENIC RISK ESTIMATES

                          SUMMARY OF CARCINOGENIC RISK ESTIMATED FOR THE ANCHOR CHEMICAL SITE

Scenario            Receptor            Present/Future     Total Risk

Ground Water

Ingestion        Onsite and/or              F            8 x 10-5*
                 Adjacent Resident

Subsurface Soil and Sediments

Ingestion        Excavation Worker          F            3 x 10-7


*Exceeds 10-6 risk

a Chemical-specific risk assessment summary information is presented in the B.

-------
                                    APPENDIX III

                             ADMINISTRATIVE RECORD INDEX

                                ANCHOR CHEMICALS SITE
                            ADMINISTRATIVE RECORD FILE
                                 INDEX OF DOCUMENTS


   1.0   SITE IDENTIFICATION

1.1   Background - RCRA and Other Information

   P.     100001 -  Map:  "Property on West John Street", prepared by
         100001    Holzmacher,  McLendon & Murrell, prepared for Jerry
                   Spiegel Associates, April 18, 1967.

   1.4   Site Investigation Reports

   P.     100002 -  Letter to Mr. Norman H. Nosenchuck, Director,
         100104    Division of Solid Waste, New York State Department
                   of Environmental Conservation, from Mr. Donald R.
                   Ganser, Project Manager, Woodward-Clyde
                   Consultants, Inc., re:  Engineering Investigations
                   at Inactive Hazardous Waste Sites in the State of
                   New York, Phase I - Preliminary Investigation,
                   Anchor Chemicals, June 3, 1983.   (Attached report:
                   untitled, prepared by Woodward-Clyde Consultants,
                   Inc.,  undated.)

   3.0   REMEDIAL INVESTIGATION

   3.2   Sampling and Analysis Data/Chain of Custody Forms

   P.     300001 -  Letter to Ms. Dorothy Allen, Project Manager, U.S.
         300321     EPA,  Region II, from Mr. Dean Anson II, Co-
                    Facility Coordinator, Anson Environmental, re:
                    Disposal of Soil and Water, Anchor Chemical Site,
                    December 20, 1991.   (Attached:  1.  Report:
                    Quality Assurance Review, The Anchor Chemical
                    Project, prepared by Environmental Standards,
                    Inc., prepared for Anson Environmental, December
                    10, 1991.  2.  Report:  untitled, prepared by
                    Environmental Standards, Inc., undated.)

     P.   300322 -  Letter to Ms. Dorothy Allen, Project Manager, U.S.
         300510    EPA, Region II,  from Mr. Dean Anson II, Co-
                   Facility Coordinator, Anson Environmental, re:
                   Enclosed data sheets for Anchor Chemical Site,
                   February 4,  1992.  (Attached:  "Validated Data,
                   All Drywells  (First Sampling), undated.)

-------
P.     300511 -  Letter to Ms. Dorothy Allen, Project Manager, U.S.
      300609    EPA, Region II, from Mr. Dean Anson II, Co-
                Facility Coordinator, Anson Environmental, re:
                Enclosed data sheets for the composite soil
                samples, April 7,  1992.  (Attached:  "Section 2,
                Analytical Results", undated.)

  P.  300610 -  Facsimile transmittal sheet to Ms. Dorothy Allen,
      300615    U.S. EPA, from Mr. Dean Anson,  Anson
                Environmental, Ltd., re:  TCLP, CLP data
                validation soil composite,  April 8, 1992.
                (Attached:  1.  Letter to Ms. Fritzi Mazzola, Anson
                Environmental, from Mr. Donald J. Lancaster,
                Senior Quality Assurance Chemist, Environmental
                Standards, Inc.,  re:  Quality assurance review of
                the data package for the TCLP analysis of Sample
                #1, #2,  #3 (composite sample),  March 25, 1992.  2.
                Report:   Section 1:  Quality Assurance Review,
                prepared by Mr. Donald J. Lancaster, Senior
                Quality Assurance Chemist,  Environmental
                Standards, Inc.,  March 25,  1992.)

P.     300616 -  Letter to Mr. Tom Taccone,  Project Manager, U.S.
      300631    EPA, Region II, from Mr. Dean Anson II, Co-
                Facility Coordinator, Anson Environmental, re:
                Enclosed validated results for the first round of
                groundwater samples, July 24, 1992.  (Attached:
                "Section 2, Analytical Results", undated.)

  P.  300632 -  Letter to Mr. Tom Taccone,  Project Manager, U.S.
      300713    EPA, Region II, from Mr. Dean Anson II, Co-
                Facility Coordinator, Anson Environmental, re:
                Enclosed validated data from soil and groundwater
                samples, August 13, 1992.   (Attached:  "Composite
                Soil Sampling from Drums (Soil Originally Brought
                onto the Site to Sand the Parking Lot)", undated.)

  P.  300714 -  Letter to Mr. Tom Taccone,  Project Manager, U.S.
      300726    EPA, Region II, from Mr. Dean Anson II, Co-
                Facility Coordinator, Anson Environmental, re:
                Enclosed validated data from groundwater samples,
                August 20, 1992.    (Attached:  Analytical results, undated.)

P.     300727 -  Letter to Mr. Jonathan Greco, Bureau of Eastern
      300776    Remedial Action,  Division of Hazardous Waste
                Remediation,  Federal Projects Section,  New York
                State Department of Environmental Conservation,
                from Mr. Dean Anson II, Anson Environmental Ltd.,
                re:  Disposal of soil cuttings, September 9, 1992.
                (Attached data, undated.)

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P.     300777 -  Letter to Mr. Tom Taccone, Project Manager, U.S.
      300789    EPA, Region II, from Mr. Dean Anson II, Co-
                Facility Coordinator, Anson Environmental, Ltd.,
                re:  Reguest for a copy of validated data,
                September 17, 1992.  (Attached:  1.  Letter to Mr.
                Tom Taccone, Project Manager, U.S. EPA, Region II,
                from Mr. Dean Anson II, Co-Facility Coordinator,
                Anson Environmental, Ltd., re:  Reguest for a copy
                of validated data, September 18, 1992.  2.
                Sampling information, undated.)

P.     300790 -  Letter to Mr. Tom Taccone, Project Manager, U.S.
      300799    EPA, Region II, from Mr. Dean Anson II, Co-
                Facility Coordinator, Anson Environmental, re:
                Validated data from the soil samples taken from
                indoor borings #3 and 4, September 21, 1992.
                (Attached data, undated.)

P.     300800 -  Letter to Mr. Tom Taccone, Project Manager, U.S.
      300820    EPA, Region II, from Mr. Dean Anson II, Co-
                Facility Coordinator, Anson Environmental, re:
                Sampling reguirements and data, September 24,
                1992.   (Attached:  "Drywell Sediment Sampling",
                undated.)

P.     300821 -  Facsimile transmittal sheet to Mr. Tom Taccone,
      300825    U.S. EPA,  from Ms. Fritzi Gros-Daillon, Anson
                Environmental, Ltd., re:  Anchor Chemical - Well
                1-S Installation Log, July 21, 1993.   (Attached:
                Sampling information, undated.)

  P.  300826 -  Facsimile transmittal sheet to Mr. Tom Taccone,
      300829    Project Manager, U.S. EPA, from Mr. Dean Anson,
                Anson Environmental, Ltd., re:  Enclosed
                corrected charts, November 3, 1993.   (Attached:
                1.  Table 3-3, "Well Development Data", undated.
                2.  Table 4-6, "Indoor Borings, OVM Readings and
                Samples Selected", undated.  3.  Table 4-10,
                "Specific Capacity Tests", undated.)
  P.  300830 -  Letter to Mr. Thomas Taccone, Project Manager,
      300847    U.S. EPA, from Mr. Dean Anson II, Co-Facility
                Coordinator, Anson Environmental, Ltd., re:
                Validated Results from Cesspool Sampling, Anchor
                Chemical Superfund Site, November 10, 1993.
                (Attached:  1.  Report:  Section 1:  Quality
                Assurance Review, prepared by Mr. LeRoy F.
                Wenrick, Quality Assurance Chemist, Environmental
                Standards, Inc., October 29, 1993.  2.  A.  Organic
                Data, undated.  3.  B.  Inorganic Data, undated.)

-------
     P.  300848 -  Letter to Mr. Kevin Kubik, U.S. EPA, from Mr. Dean
         300860    Anson II, Co-Facility Coordinator, Anson
                   Environmental, Ltd., re:  Additional information
                   prepared by the data validator for the samples
                   analyzed from indoor borings #1 and #2, January 3,
                   1994.  (Attached:  1.  Report:  Section 1:  Quality
                   Assurance Review, prepared by Mr. William S.
                   Strohben, Jr., Quality Assurance Chemist,
                   Environmental Standards, Inc., March 2, 1992.  2.
                   "Section 6, Case Narratives and Chain-of-
                   Custodies", undated.)
P.
P.   300861 -  "Completed Analysis Report, Anchor Chemical",
    300862    March 31,  1995.

P.   300863 -  Letter to Ms. Alison Devine, Region II ARCS
    300869    Project Officer,  U.S. EPA, from Mr. Robert D.
              Goltz, P.E., ARCS II Program Manager,  CDM Federal
              Programs Corporation, re:  Letter Report, Summary
              of Split Sampling Results of Soil and Groundwater
              Samples, Anchor Chemical Site,  Hicksville, New
              York, June 15, 1995.  (Attached report:  Letter
              Report, Summary of Split Sampling Results of Soil
              and Groundwater Sampling, Anchor Chemical Site,
              Hicksville, New York, prepared by CDM Federal
              Programs Corporation, prepared for U.S. EPA, June
              15, 1995.)

    300870 -  Facsimile transmittal sheet to Mr. Tom Taccone,
    300871    U.S. EPA,  from Mr. Dean Anson,  Anson
              Environmental, Ltd., re:  Table 1-2, Anchor
              Chemical,  July 20, 1995.   (Attached:  Table 1-2,
              "Volatile Organic Compounds Detected at
              Quantifiable Concentrations in Groundwater at the
              Anchor Chemical Site (concentrations in ug/L)(Roux
              1991)", undated.)
   3.3   Work Plans
         300872 -  Plan:  Work Plan Remedial Investigation and
         301139    Feasibility Study, Anchor Chemical Site,
                   Hicksville, New York, prepared by Roux Associates,
                   Inc., prepared for Spiegel Associates, May 4, 1990.

         301140 -  Plan:  Project Operations Plan, Remedial
         301309    Investigation, Anchor Chemical Site, Hicksville,
                   New York, prepared by Roux Associates, Inc.,
                   prepared for Spiegel Associates, April 10, 1991.

         301310 -  Plan:  Work Plan, Remedial Investigation, Anchor
         301490    Chemical Site, Hicksville, New York, prepared by
                   Roux Associates, Inc., prepared for Spiegel
                   Associates, April 10, 1991.

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3.4   Remedial Investigation Reports

P.     301491 -  Guidance Document:  Investigation of Contaminated
      301656    Aguifer Segments, Nassau County, New York,
                prepared by Nassau County Department of Health,
                and Dvirka and Bartilucci, Consulting Engineers,
                June 1986.
P.     301657 -  Letter to Ms. Dorothy Allen, Project Manager, U.S.
      301700    EPA,  Region II,  from Mr. Richard G. Leland,
                Rosenman & Colin,  re:  Forwarding enclosed "Tank
                Closure Report",  September 17,  1991.  Attached
                report:  Tank Closure Report, prepared by Roux
                Associates, Inc.,  prepared for Spiegel Associates,
                August 23, 1991.)

  P.  301701 -  Letter to Ms. Dorothy Allen, Project Manager, U.S.
      301789    EPA,  Region II,  from Mr. Dean Anson II, Co-
                Facility Coordinator, Anson Environmental, re:
                Enclosed "Quality Assurance Review, The Anchor
                Chemical Project" Report, April 22, 1992.
                (Attached:  1.  Letter to Mr. Dean Anson, Anson
                Environmental, from Mr. Rock J. Vitale, Quality
                Assurance Specialist/Principal, Environmental
                Standards, Inc.,  re:  Enclosed "Quality Assurance
                Review, The Anchor Chemical Project" Report,  April
                16,  1992.  2.  Report:  Quality Assurance Review,
                The Anchor Chemical Project, prepared by
                Environmental Standards, Inc.,  prepared for Anson
                Environmental, April 16, 1992.)

  P. 301790 -   Letter to Mr. Tom Taccone, ERRD/NYCSB2-W, U.S.
      301803    EPA,  from Mr. Arthur Block, Senior Regional
                Representative,  Public Health Service, Agency for
                Toxic Substances  and Disease Registry, Department
                of Health and Human Services, re:  Revised Site
                Review and Update (SRU) for Anchor Chemicals/Lith
                Kem-Ko, Hicksville,  Nassau County, NY, December 6,
                1994.  (Attached report:  Site Review and Update,
                Anchor/Lith Kem-Ko,  Hicksville, Nassau County, New
                York, prepared by The New York State Department of
                Health, November 16, 1994.)

P.     301804 -  Report:  Volume 1, Remedial Investigation Report,
      301967    Anchor Chemical Site, Hicksville, New York,
                prepared by Anson Environmental Ltd.,  prepared for
                K.B.  Company, March 1995.

  P.  301968 -  Report:  Volume 2, Remedial Investigation Report,
      302032    Appendix A - D,  Anchor Chemical Site,  Hicksville,
                New York, prepared by Anson Environmental Ltd.,
                prepared for K.B.  Company, March 1995.

-------
  P.  302033 -  Report:  Volume 3, Remedial Investigation Report,
      302170    Appendix E, Anchor Chemical Site, Hicksville, New
                York, prepared by Anson Environmental Ltd. ,
                prepared for K.B. Company, March 1995.

  P.  302171 -  Report:  Volume 4, Remedial Investigation Report,
      302282    Appendix F - M, Anchor Chemical Site, Hicksville,
                New York, prepared by Anson Environmental Ltd.,
                prepared for K.B. Company, March 1995.

  P.  302283 -  Report:  Remedial Investigation Report Supplement,
      302318    Anchor Chemical Site, Hicksville, New York,
                prepared by Anson Environmental Ltd., prepared for
                K.B. Company, April 1995.

P.     302319 -  Letter to Mr. Arthur D. Sanders, President,  K.B.
      302633    Company, c/o Jerry Speigel Associates, Mr. Dean
                Anson, Anson Environmental, and Richard G. Leland,
                Esguire, Rosenman and Colin, from Ms. Carole
                Petersen, Chief, New York/Caribbean Superfund
                Branch II, U.S. EPA, re:  Anchor Chemical Superfund
                Site; Final Risk Assessment, June 2, 1995.
                (Attached report:  Final Risk Assessment, Anchor
                Chemical Site, Hicksville, New York, prepared by
                TRC Environmental Corporation, prepared for
                Emergency and Remedial Response Division, U.S.
                EPA, April 1, 1994.)

3.5   Correspondence

P.     302634 -  Letter to Ms. Dorothy Allen, Project Manager, U.S.
      302698    EPA, Region II, from Mr. Dean Anson II, Co-
                Facility Coordinator, Anson Environmental, and Mr.
                Stanley Sucharski, Co-Facility Coordinator,  Anson
                Environmental, re:  Field conditions reguiring the
                modification of the Project Operations Plan,
                January 28, 1992.   (Attached:  1.  Marine Pollution
                Control, Well Experience Log, Boring Logs; 2.
                Boring Logs for MW-1D; 3.  Description of Soil
                Sample MW1-D  (122"); 4.  Resumes of Individuals who
                Examined the Samples from MW-1D; 5.  Drilling
                Contractor Contacts, Telephone Conversation Logs;
                6.  Validated Laboratory Data; 7.  Unvalidated
                Laboratory Data.)

P.     302699 -  Letter to Mr. Bernard J. Bottomley, Director,
      302703    Engineering and Administrative Services, Newsday,
                from Mr. Dean Anson II, Anson Environmental, re:
                Information about Drywell #2 at Anchor Chemical,
                March 12, 1992.   (Attached:  1.  Letter to Mr. Art
                Sanders, Spiegel Associates, from Mr. Bernard J.
                Bottomly, Newsday, re:  Anchor Chemical
                information, February 14, 1992.  2.  Letter to
                Janette Payne, Esguire, Times-Mirror, from
                Richard G. Leland, Esguire, Rosenman and Colin,
                re:  Anchor Chemical documents, February 5,  1992.)

-------
      302704 -  Letter to Mr. Tom Taccone, Project Manager, U.S.
      302704    EPA,  Region II,  from Mr. Dean Anson II, Co-
                Facility Coordinator, Anson Environmental, re:
                Validated data for soil cuttings drummed during
                installation of the monitoring wells and the
                indoor borings,  September 14, 1992.

      302705 -  Letter to Mr. Dean Anson, Anson Environmental,
      302707    Ltd., from Ms. Carole Petersen,  Chief,
                NY/Caribbean Superfund Branch II, U.S.  EPA, re:
                Anchor Chemical Superfund Site;  Second Round of RI
                Sampling; Format for Submission of RI Data,
                September 30, 1992.  (Attached:   "Risk Assessment
                Data Format Reguirements", prepared by TRC
                Environmental Corporation, undated.)

      302708 -  Facsimile transmittal sheet to Ms. Dorothy Allen,
      302709    U.S.  EPA, from Mr. Dean Anson, Anson
                Environmental, Ltd., re:  Anchor Chemical, April
                30,  1993.  (Attached letter to Ms. Dorothy Allen,
                Project Manager, U.S. EPA, from Mr. Dean Anson II,
                Co-Facility Coordinator, Anson Environmental Ltd. ,
                re:   120 drums of soil cuttings scheduled for
                removal on May 10th and llth, April 28, 1993.)

  P.  302710 -  Letter to Mr. Thomas Taccone, U.S. EPA, from Mr.
      302711    Dean Anson II, Co-Facility Coordinator, Anson
                Environmental, Ltd., re:  Direction of Groundwater
                Flow, Anchor Chemical Superfund Site, June 21,
                1993.
  P.  302712 -  Letter to Mr. Thomas Taccone, U.S. EPA, from Mr.
      302716    Dean Anson II,  Co-Facility Coordinator, Anson
                Environmental,  Ltd., re:  Direction of Groundwater
                Flow, Anchor Chemical Superfund Site, July 13,
                1993.  (Attached:  1.  Map:  "West John Street,
                Monitoring Well Location Plan,  Hicksville, New
                York", prepared by Mr. Albert W. Tay, April 21,
                1992.  2.  Map:  "West John Street, Monitoring Well
                Location Plan,  Hicksville, New York", prepared by
                Mr. Albert W. Tay,  April 21, 1992.  3.  "Typical
                Leeching Pool Detail", undated.)

P.     302717 -  Letter to Mr. Arthur D. Sanders, President, K.B.
      302726    Company,  c/o Jerry Spiegel Associates, Richard G.
                Leland, Esguire, Rosenman and Colin, and Mr. Dean
                Anson, Anson Environmental, Ltd., from Ms. Carole
                Petersen, Chief, NY/Caribbean Superfund Branch II,
                U.S. EPA, re:  EPA Comments on the Draft Remedial
                Investigation Report for the Anchor Chemical
                Superfund Site, August 5, 1993.

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P.     302727 -  Letter to Mr. Thomas Taccone, Work Assignment
      302729    Manager,  U.S. EPA, Emergency and Remedial Response
                Division, from Mr. Andre Bridgett, Project
                Manager,  TRC Environmental Corporation, re:
                Ground Water Flow Direction and Sampling Needs,
                August 24, 1993.  (Attached map:  "West John
                Street, Monitoring Well Location Plan, Hicksville,
                New York", prepared by Mr. Albert W. Tay, April
                21, 1992.)

  P. 302730 -   Letter to Mr. Thomas Taccone, Work Assignment
      302732    Manager,  U.S. EPA, Emergency and Remedial Response
                Division, from Mr. Andrew G. Hargens, TRC
                Geologist, TRC Environmental Corporation, re:
                Clarification of Observed Field Sampling
                Procedures,  December 7, 1993.

P.     302733 -  Letter to Mr. Thomas Taccone, Project Manager,
      302734    U.S. EPA, from Mr. Dean Anson II, Co-Facility
                Coordinator, Anson Environmental, Ltd., re:
                Anchor Chemical Superfund Site,  Cesspool Sampling
                Locations, February 15, 1994.   (Attached map:
                "500 West John Street, Cesspool Sampling
                Locations",  prepared by Anson Environmental, Ltd.,
                undated.)
P.     302735 -  Letter to Mr. Tom Taccone, EPA Work Assignment
      302736    Manager,  U.S. EPA, Emergency and Remedial Response
                Division, from Ms. Susan W. Stoloff, Project
                Manager,  TRC Environmental Corporation, re:
                Tentatively Identified Compounds 1,4-Dioxane and
                2-Butoxyethanol,  April 5, 1994.

  P. 302737 -   Letter to Mr. Arthur D. Sanders, President, K.B.
     302742     Company,  c/o Jerry Spiegel Associates,  Richard G.
                Leland,  Esguire,  Rosenman and Colin, Mr. Dean
                Anson, Anson Environmental, and S. Sucharski,
                Blasland, Bouck and Lee, from Ms. Carole Petersen,
                Chief, NY/Caribbean Superfund Branch II, U.S. EPA,
                re:  EPA comments on the Revised Draft Remedial
                Investigation Report for the Anchor Chemical
                Superfund Site, May 6, 1994.

  P.  302743 -   Letter to Mr. Tom Taccone, Project Manager, U.S.
      302743     EPA, from Richard G.  Leland, Esguire,  Rosenman and
                 Colin,  re:  EPA Comments on the Revised Draft
                 Remedial Investigation Report for the Anchor
                 Chemical Superfund Site, May 12, 1994.

  P.  302744 -  Letter to Mr. Thomas Taccone, U.S. EPA, Region II,
      302747    from Mr.  Dean Anson II, Anson Environmental, Ltd.,
                re:  Responses to EPA May 6, 1994 Comments on the
                Revised Draft Remedial Investigation Report for
                the Anchor Chemical Superfund Site, May 31, 1994.

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  P.  302748 -  Letter to Richard G. Leland, Esquire, Rosenman and
      302749    Colin, from James Doyle, Esquire, Assistant
                Reqional Counsel, Office of Reqional Counsel, U.S.
                EPA, re:  Draft Remedial Investiqation Report,
                Anchor Chemical Superfund Site, June 29, 1994.

P.     302750 -  Facsimile transmittal sheet to James Doyle,
      302752    Esquire, U.S. EPA, from Richard G. Leland,
                Esquire, Rosenman and Colin, re:  Enclosed letter
                reqardinq the draft remedial investiqation report
                for Anchor Chemical Superfund Site, July 11, 1994.
                (Attached letter to James Doyle, Esquire,
                Assistant Reqional Counsel, Office of Reqional
                Counsel, U.S. EPA, Reqion II, from Richard G.
                Leland,  Esquire, Rosenman and Colin, re:  Draft
                Remedial Investiqation Report, Anchor Chemical
                Superfund Site, July 11, 1994.)

P.     302753 -  Letter to Richard G. Leland, Esquire, Rosenman and
      302754    Colin, from James Doyle, Esquire, Assistant
                Reqional Counsel, Office of Reqional Counsel, U.S.
                EPA, re:  Issues at the Anchor Chemical Superfund
                Site, Hicksville, New York, July 18, 1994.

P.     302755 -  Letter to Mr. Thomas Taccone, New York/Caribbean
      302807    Compliance Branch, U.S. EPA, from Mr. Dean Anson
                II, Co-Facility Coordinator, Anson Environmental,
                Ltd., re:  Remedial Investiqation Report
                Revisions, Anchor Chemical Superfund Site, Auqust
                3,  1994.  (Attached:  "Anchor RI Response", July 1994.)

P.     302808 -  Letter to Mr. Marsden Chen, Section Chief, New
      302812    York State Department of Environmental
                Conservation, Federal Project Section, and Mr.
                Thomas Taccone, Project Manaqer, U.S. EPA, Reqion
                II, from Helen Collier Mauch, Esquire, Rosenman
                and Colin, re:  Enclosed memorandum prepared by
                Anson Environmental Ltd. settinq forth the
                technical basis for request for no further action
                in connection with Tank 14, Auqust 29, 1994.
                (Attached letter to Richard Leland, Esquire,
                Rosenman and Colin, from Mr. Dean Anson II, Anson
                Environmental, Ltd., re:  Tank Investiqation,
                Anchor Chemical Site, Auqust 29, 1994.)

P.     302813 -  Letter to Mr. Arthur D. Sanders, President, K.B.
      302817    Company, c/o Jerry Spieqel Associates, Richard G.
                Leland,  Esquire, Rosenman and Colin, Mr. Dean
                Anson, Anson Environmental, and S. Sucharski,
                Blasland, Bouck and Lee, from Ms. Carole Petersen,
                Chief, NY/Caribbean Superfund Branch II, U.S. EPA,
                re:  Anchor Chemical Superfund Site, EPA Comments
                on the Revised Draft Remedial Investiqation
                Report,  September 30, 1994.

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302818 -  Letter to Mr. Tom Taccone, New York/Caribbean
302818     Compliance Branch, U.S. EPA, from Mr. Dean Anson
          II,  Co-Facility Coordinator, Anson Environmental,
          Ltd., re:  Monthly Report for September, 1994,
          Anchor Chemical Superfund Site,  October 4,  1994.

302819 -  Letter to Mr. Thomas Taccone, Remedial Project
302821    Manager,  U.S. EPA, from Ms. Susan E. Boone, Work
          Assignment Manager, CDM Federal Programs
          Corporation, re:  Evaluation of Additional
          Proposed Soil Borings Upon Baseline Risk
          Assessment, Oversight of Expanded Remedial
          Investigation Activities, Anchor Chemical Site,
          Hicksville, New York, December 14, 1994.

302822 -   Letter to Mr. Thomas Taccone, U.S. EPA, Region II,
302841     from Mr. Dean Anson II, Co-Facility Coordinator,
           Anson Environmental, Ltd., re:   Responses to EPA
           September 30, 1994 Comments on Revised Remedial
           Investigation Report,  Anchor Chemical Site,
           December 28, 1994.  (Attached:   Information
           regarding the Anchor Chemical Site)

302842 -   Letter to Mr. Fred Elsen, U.S.  EPA, from Ms.
302842     Fritzi Mazzola Gros-Daillon, Anson Environmental,
           Ltd., re:  Analytical Standards for 1,4-Dioxane,
           Anchor Chemical Superfund Site, Hicksville, New
           York, January 13, 1995.

302843 -   Letter to Mr. Thomas Taccone, Project Manager,
302843     U.S. EPA, NY/Caribbean Superfund Branch II, from
           Helen Collier Mauch, Esguire, Rosenman and Colin,
           re:  Reguest to provide EPA's comments on the
           revised remedial investigation report ahead of
           schedule, January 30,  1995.

302844 -   Letter to Helen Collier Mauch,  Esguire, Rosenman
302844     and Colin, from James Doyle, Esguire, Assistant
           Regional Counsel, Office of Regional Counsel, U.S.
           EPA, re:  Draft Remedial Investigation Report
           Comment Letter, Anchor Chemical Superfund Site,
           February 1, 1995.

302845 -   Letter to Mr. Arthur D. Sanders, President, K.B.
302847     Company, c/o Jerry Spiegel Associates, Richard G.
           Leland,  Esguire, Rosenman and Colin, and Mr. Dean
           Anson, Anson Environmental, from Ms. Carole
           Petersen, Chief, NY/Caribbean Superfund Branch II,
           U.S. EPA, re:  Anchor Chemical Superfund Site, EPA
           Comments on the Revised Draft Remedial
           Investigation Report,  February 21, 1995.

302848 -   Letter to Mr. Thomas Taccone, U.S. EPA, Region II,
302848     from Mr. Dean Anson II, Anson Environmental, Ltd.,
           re:  Anchor Chemical Superfund Site, Supplemental
           Report to RI, April 12, 1995.

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6.0   STATE COORDINATION

6.3   Correspondence

P.     600001 -  Letter to Ms. Dorothy Allen, Eastern NY/Caribbean
      600001    Section II, U.S. EPA, Region II, from Mr. Jonathan
                Greco, Federal Projects Section, Bureau of Eastern
                Remedial Action, Division of Hazardous Waste
                Remediation, New York State Department of
                Environmental Conservation, re:  Disposal of
                Investigation Derived Soils, Anchor Lith Kem-ko
                Site, December 1, 1992.

P.     600002 -  Letter to Mr. Thomas Taccone, Western NY/Caribbean
      600005    Section II, U.S. EPA, Region II, from Mr. Jonathan
                Greco, Bureau of Eastern Remedial Action, Division
                of Hazardous Waste Remediation, New York State
                Department of Environmental Conservation, re:
                Draft Remedial Investigation Report, Anchor
                Chemical Site, June 9, 1993.

P.     600006 -  Letter to Mr. Thomas Taccone, Western NY/Caribbean
      600021    Section II, U.S. EPA, Region II, from Mr. Jonathan
                Greco, Bureau of Eastern Remedial Action, Division
                of Hazardous Waste Remediation, New York State
                Department of Environmental Conservation, re:
                Groundwater Flow Direction, Anchor Chemical Site,
                June 22, 1993.   (Attached:  Anchor Chemical Site
                information, undated.)
      600022 -  Letter to Mr. Jonathan Greco, Bureau of Eastern
      600023    Remedial Action, Division of Hazardous Waste
                Remediation, New York State Department of
                Environmental Conservation, from Mr. Thomas
                Taccone, Project Manager, Western New York Section
                II, U.S. EPA, re:  NYSDEC's Comments on the Anchor
                Chemical Draft RI Report, August 12, 1993.

      600024 -  Letter to Mr. Tom Taccone,  Western NY/Caribbean
      600024    Section II, U.S. EPA, Region II, from Mr. Jonathan
                Greco, Bureau of Eastern Remedial Action, Division
                of Hazardous Waste Remediation, New York State
                Department of Environmental Conservation, re:
                Additional Groundwater Sampling, Anchor Lith Kem-
                Ko, October 5, 1993.

      600025 -   Letter to Mr. Tom Taccone, Western NY/Caribbean
      600026     Section II, U.S. EPA, Region II, from Mr. Jonathan
                 Greco, Bureau of Eastern Remedial Action, Division
                 of Hazardous Waste Remediation, New York State
                 Department of Environmental Conservation, re:
                 Draft Final Remedial Investigation, Anchor Lith
                 Kem-Ko, November 16, 1993.

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   P.    600027 -   Letter to Ms. Dorothy Allen, U.S. EPA, Region II,
         600028     from Mr. Michael J. Hughes, Environmental Health
                    Specialist II, Bureau of Toxic Substance
                    Assessment, State of New York Department of
                    Health, re:  Preparation of a Site Review and
                    Update  (SRU)  for the Anchor Lith Kem-Ko Site,
                    January 21, 1994.

   P.    600029 -   Letter to Mr. Thomas Taccone, U.S. EPA, Region II,
         600029     from Mr. Jonathan Greco, Engineering Geologist I,
                    Bureau of Eastern Remedial Action, Division of
                    Hazardous Waste Remediation, New York State
                    Department of Environmental Conservation, re:
                    Dean Anson's May 31, 1994 Response to Comments on
                    RI, Anchor Lith Kem-Ko Site, June 6, 1994.
P.     600030 -
      600030
Letter to Mr. Tom Taccone, Western NY/Caribbean
Section II, U.S. EPA, Region II, from Mr. Jonathan
Greco, Bureau of Eastern Remedial Action, Division
of Hazardous Waste Remediation, New York State
Department of Environmental Conservation, re:
Future Actions at the Anchor Lith Kem-Ko Site, May 2,
   P.    600031 -   Letter to Mr. Sal Ervolina, Director, Bureau of
         600031     Eastern Remedial Action, Division of Hazardous
                    Waste Remediation, New York State Department of
                    Environmental Conservation, from Ms. Carole
                    Petersen, Chief, New York/Caribbean Superfund
                    Branch II, U.S. EPA, re:  Draft Proposed Plan,
                    Anchor Chemical Site, June 9, 1995.

   P.    600032 -   Letter to Ms. Kathleen Callahan, Director,
         600032     Emergency and Remedial Response Division, U.S.
                    EPA, Region II, from Mr. Michael O'Toole, Jr.,
                    Director, Division of Hazardous Waste Remediation,
                    New York State Department of Environmental
                    Conservation, re:  Anchor Chemical Site, Proposed
                    Plan, July 7, 1995.

   P.    600033 -  Letter to Mr. Tom Taccone, Western NY/Caribbean
         600033    Section II, U.S. EPA, Region II, from Mr. Jonathan
                   Greco, Bureau of Eastern Remedial Action, Division
                   of Hazardous Waste Remediation, New York State
                   Department of Environmental Conservation, re:
                   Technical Comments on Proposed Plan - Anchor
                   Chemical Site, July 10, 1995.
                                                                          1995.

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7.0
      ENFORCEMENT
7.3   Administrative Orders

P.     700001 -  Administrative Order on Consent, In the Matter of
      700029    Anchor Chemical, K.B. Company, Respondent, Index
                No. II CERCLA-90208, June 2, 1989.  (Attached:
                "Appendix I, Order on Consent, Index Number II
                CERCLA-90208, Statement of Work for 500 West John
                Street,  Hicksville, New York", prepared by Roux
                Associates, Inc., prepared for Rosenman & Colin,
                April 26, 1989.)

P.     700030 -  Administrative Order, In the Matter of Anchor
      700043    Chemical, Chessco Industries, Inc., Respondent,
                Index No. II CERCLA-90218, August 3, 1989.

P.     700044 -  Administrative Order, In the Matter of the Anchor
      700056    Chemical Site, Anchor/Lith-Kem Ko, Inc.,
                Respondent, Index No. II CERCLA-20205, March 31, 1992.

P.     700057 -  Administrative Order On Consent, In the Matter of
      700081    the Anchor Chemical Site, Anchor Lith/Kem Ko.,
                Inc., and Chessco Industries, Respondents, Index
                No. II CERCLA-94-0220,  August 29, 1995.

P.     700082 -  Administrative Order, In the Matter of the Anchor
      700102    Chemical Site, K.B. Company, Respondent, Index
                Number II-CERCLA-95-0209, August 29, 1995.

  10.0  PUBLIC PARTICIPATION

  10.2  Community Relations Plans

P.     1000001 - Letter to Ms. Cathy Moyik, Regional Project
      1000033   Officer, Emergency and Remedial Response Division,
                U.S. EPA, from Mr. Charles Feinberg, Regional
                Manager, Alliance Technologies Corporation, re:
                Revised Final Community Relations Plan, June 7,
                1991.   (Attached report:  Community Relations
                Plan, Anchor Chemical Site, Hicksville, Nassau
                County,  New York, Community Relations Support,
                prepared by Alliance Technologies Corporation,
                prepared for Emergency and Remedial Response
                Division, U.S. EPA, June 6, 1991.)

10.6  Fact Sheets and Press Releases
P.     1000034 - Fact Sheet:  Superfund Program Fact Sheet, Anchor
      1000041   Chemical Site,  Hicksville, New York, EPA Begins
                Remedial Investigation at the Anchor Chemical
                Superfund Site, prepared by U.S. EPA, Region II,
                August 1991.

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                             APIENDIX IV

                            STATE IiETTER OF CONCURRENCE


    DIRECTOR'S OFFICE        Fax:  518-485-8404         Sep 29  '95      15:

 NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION <0295254C>
 50 Wolf Road, Albany, New York  12233
                                                     Michael D. Zagata
                                                     Commissioner

                           SEP 29 1995

Ms. Kathleen Callahan
Director
Emergency & Remedial Response Division
U.S. Environmental Protection Agency
Region II
290 Broadway
New York, NY 10007-1866

                      Re:  Anchor Chemical Site ID No. 130018
                        Record of Decision

Dear Ms. Callahan:

       The New York State Department of Environmental Conservation has revi
decision for the Anchor Chemical site.  The Department concurs with the sel
action as it is detailed in the above-referenced document.

       If you have any questions, please contact Mr. Jonathan Greco, of my
457-3976.


                              Sincerely,
                              Michael J. O'Toole, Jr.
                              Director
                              Division of Hazardous Waste Remediation

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                       APPENDIX V

                  RESPONSIVENESS SUMMARY

                      TABLE OF CONTENTS
I.     RESPONSIVENESS SUMMARY OVERVIEW  	

II.    BACKGROUND OF COMMUNITY INVOLVEMENT  	

III.  COMPREHENSIVE SUMMARY OF COMMENTS AND RESPONSES  .  .  .

      A.  SUMMARY OF EPA'S RESPONSES TO WRITTEN COMMENTS

      B.  SUMMARY OF EPA'S COMMENTS RECEIVED AT THE  PUBLIC
          MEETING  	
      C.  REMAINING CONCERNS

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I.    RESPONSIVENESS SUMMARY OVERVIEW

This Responsiveness Summary provides a summary of citizen comments and concerns and the responses by the U.S.
Environmental Protection Agency  ("EPA") to those comments regarding the Remedial Investigation  (RI) and Risk
Assessment Reports and Proposed Plan for the Anchor Chemical Superfund Site  (the "Site").  All comments
summarized in this document have been considered in EPA' s final decision for selection of a no further action
remedy for the Site.

EPA's public comment period, which started on August 23, 1995 and ended on September 21, 1995, provided
interested parties with the opportunity to comment on the RI, Risk Assessment and Proposed Plan for the Site.
A public meeting was held to discuss implementation of the Site remedy (i.e. removal of contaminated soil and
sediments from four drywells and no further action).  The meeting was held at the Hicksville Public Library,
in Hicksville, New York on September 12, 1995 at 7:00 p.m.

An evaluation of all available data, the findings of the RI conducted at the Site,  EPA's Risk Assessment, and
other supporting data and documentation indicate that the Site risks are within EPA's acceptable risk range
and that a no further action decision is protective of human health and the environment.

Although the risks posed by the Site contamination are within the acceptable risk range, four dry wells on
Site are contaminated with chromium, lead, 1,1,1 trichloroethane  (1,1,1-TCA) and other volatile organic
compounds (VOCs).   Groundwater samples from several monitoring wells on Site also showed concentrations of
chromium and 1,1,1-TCA, which were above MCLs.  The contaminated soils and sediments from the dry wells were
removed in order to prevent further groundwater contamination.  The excavated materials will be disposed of
at a Resource Conservation and Recovery Act (RCRA) approved facility.  Groundwater and soil     samples will
be collected at the Site and analyzed to assess the effectiveness of the removal action.  Upon completion of
the removal action, EPA will take no further action at the Anchor Chemical Superfund Site.

During the public meeting, the local community reaction to the preferred alternative was, for the most part,
favorable. However, there was a concern raised by the Nassau County Department of Health about the potential
for contamination to affect public and private drinking water wells, which are downgradient from the Site.
The nearest public supply well is approximately one mile downgradient.  Also, the Site is in an area which is
zoned for industry.  According to the Nassau County Department of Buildings, the nearest area which is zoned
for residential development is approximately one half mile downgradient from the Site.  Because of the large
distances from the Site to the nearest public wells,  any contamination which reaches the wells would be
greatly reduced,  such that any contaminants would be well below MCL levels.

II.   BACKGROUND ON COMMUNITY INVOLVEMENT

During the course of the RI and Proposed Plan, EPA has sought to promote community awareness of activities at
the Anchor Chemical Site through local newspaper articles, fact sheets, press releases, public notices and
public information meetings.

EPA heard from only a few members of the community and local public officials.  Public meetings were held in
the Community Room of the Hicksville Public Library,  Hicksville, New York on August 21, 1991, and September
12, 1995.

EPA's initiated its community relations efforts by developing a Community Relations Plan in October 1990,
which included an outline of community concerns, reguired and suggested community relations activities, and a
comprehensive list of federal, state, and local contacts.  Site information repositories were
established at EPA' s Region II office in New York City and the Hicksville Library in the Town of Oyster Bay,
New York.

To obtain public input on the RI and the proposed remedy, a public comment period was established from August
23, 1995, to September 21, 1995.  A public notice appeared in Newsday on August 23, 1995, and in the
Hicksville Illustrative News on August 25, 1995.  The public meeting was held on September 12, 1995.

Approximately 15 people attended the meeting.   The audience consisted of residents, and state and local

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government officials. A summary of the questions posed during the meeting is included in the following
section.

III.  COMPREHENSIVE SUMMARY OF COMMENTS AND RESPONSES

Public comments on the Proposed Plan received from August 23, 1995 through September 21, 1995 are summarized
and addressed below.  Section A summarizes the written comments received during the public comment period.
Section B summarizes those comments received at the public meeting held on September 12, 1995.

A.    SUMMARY OF EPA's RESPONSES TO WRITTEN COMMENTS

Comments from State Senator Carl L. Marcellino

Comment 1:  Who has oversight responsibility for the round of groundwater samples after the drywell removal
action is completed?

EPA Response:  The U.S. Environmental Protection Agency,  Region II.

Comment 2:  Has the air quality issue been addressed?  Also, what about asbestos contamination of the
building?

EPA Response:  Air quality monitoring was performed to determine the concentration of VOCs on Site during the
field sampling portion of the Remedial Investigation.  This included monitoring personal space as well as the
ambient air around samples obtained.  The monitoring did not reveal any problems.

Asbestos was not handled at the Site.  However, there may be some asbestos in the building, which is
currently being used as a warehouse for used machinery.  In the event that the building is demolished,
asbestos-containing material and debris would be regulated under the Clean Air Act.  Any asbestos removal,
would be the responsibility of the building owner.

Comments from the Nassau County Department of Health

Comment 1:  The preferred alternative should be modified to include off-Site monitoring of wells to determine
if groundwater contamination has migrated downgradient of the Site.  The Site is located in close proximity
to the Westbury Water District supply wells No. 12 and 12A.

EPA Response:  EPA does not believe that off-Site groundwater monitoring is needed.  District public water
supply wells 12 and 12A are each approximately 1 mile downgradient from the Site.  As contaminated
groundwater moves off Site, the concentration of contaminants will decrease as the "plume" spreads out and
diffuses.  At a distance of one mile downgradient, the concentration of VOCs from the site should be well
below the Maximum Contaminant Levels for drinking water.   In addition,  because the area in which the Anchor
Site is located is zoned for industry, one would expect that other sources of contamination exist between the
Site and any potentially affected wells.  One would not be able to determine the separate contributions of
other potential sources from the Anchor Site.  In addition, the Nassau County Health Department periodically
monitors public supply wells under existing programs, i.e., the Safe Drinking      Water Act.

Comment 2:  A private well survey should be performed to determine if any private supply or irrigation wells
are present within one-half mile downgradient of the site.  If residential private wells are located, water
samples should be collected and analyzed for VOCs and metals.

EPA Response :   According to the Zoning and Planning Examination Division of the Nassau County Department of
Buildings, the nearest residential zone downgradient from the Site is located more than one-half mile in a
downgradient direction from the Site.  As such, no private well survey will be conducted. It should also be
noted that the NYSDOH has a program where they can sample and analyze private wells in the vicinity of
hazardous waste sites.

Comment 3:  All drywell clean-outs should be performed using the requirements for potential vapor emissions

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which are outlined in a New York State Department of Health (NYSDOH) procedures manual.

EPA Response:  EPA has reviewed the referenced requirements for responding to potentially harmful vapor
emissions and will require that they be followed durinq the drywell removals.

Comment 4:  Has the contamination from this Site reached the public drinkinq supply?

EPA Response :   Groundwater at the Site flows to the southwest. The nearest public water supply wells are
located 1.2 and 1.3 miles downqradient from the Site.  No contamination has been traced in the public water
supply system to the current contamination at the Anchor Chemical site.  These wells are sampled periodically
by the Nassau County Health Department. Groundwater contaminant concentrations identified at the Site would
diffuse and siqnificantly diminish by the time they reached (if they reached) the drinkinq wells.  In
addition, there may be other sources of contamination located between the Anchor Chemical site and the public
supply wells, thereby precludinq the specific identification of any contaminants detected.

B.    SUMMARY OF EPA's RESPONSES TO COMMENTS RECEIVED AT THE PUBLIC MEETING

Comment 1:  EPA stated at the September 12, 1995 meetinq that soils under tank #14 were sampled to determine
the presence of 2-butoxyethanol.  Since the contaminant was not detected at this location, where did it come
from?

EPA Response :   The presence of 2-butoxyethanol in the soil probably resulted from leaks and spills durinq
Site operations. The compound does not occur naturally in soil.

Comment 2:  At what point in the investiqation process is it determined that the problem is at its worst in
order to properly remediate, or has it dissipated before there is an opportunity to remediate?

EPA Response:  In the case of the Anchor Chemical Site, the hiqhest concentrations of contaminants have
already occurred. Soil and qroundwater samples collected from 1982 to 1985 showed hiqher concentrations of
VOC contamination.  Since the tanks were sealed, levels of contamination have been substantially reduced.
This particular source of contamination to the qroundwater has been eliminated, and any contamination in the
qroundwater has been mitiqated.

Comment 3:  Has a study been performed on the incidences of cancer in the area around the Site?  Are there
any fiqures available on whether the cancer rate is hiqher in this area because of Site operations or
contamination?

Response:  A representative of the Nassau County Health Department responded at the September 12, 1995,
meetinq by statinq that the Department has a cancer reqistry for all cancer cases listed in the County or
locally.  While the County does not perform cancer assessments, the New York State Department of Health does.
Such a study has been performed for this area.  In sum, the results show that there are no elevated levels of
cancer associated with this Site above what would be expected for this area.

Comment 4:  Reqardinq removal of soils from the drywells, how deep and wide are the wells and how much soil
is expected to be removed?  Finally, what is/are the determininq factor(s) to ascertain that the correct
amount of soil has been removed?

EPA Response :   Drywells at the Site are approximately 2 feet in diameter and extend to a depth of
approximately 17 feet below land surface (BLS).  EPA proposes to remove approximately 2 feet of soil from 4
pre-existinq drywells.  This should be about 2 feet below the bottom concrete rinq of each drywell, or 19 ft
BLS. The remaininq soils and sediment will be sampled and analyzed for contamination.  Sample data collected
for the Remedial Investiqation show that the contaminants are present in hiqher concentrations near the
surface; concentrations diminished as samples were drawn from increasinqly qreater depths.

Ultimately, soils will be removed at a depth of approximately 19 feet BLS in such a fashion that it allows
the drywell to remain structurally intact.   (Excessive soil removal may cause the walls of the drywell to
slump.)   Groundwater samples will be taken 6-12 months after the removal action to confirm the effectiveness

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of the soil removal from the drywells.

Comment 5:  While EPA proposes to remove soils below the concrete base of the drywells,  what consideration is
being given to the potential for contamination to reside in soils on the sides of the drywells?

EPA Response:  Results of the Remedial Investigation show that contaminants are concentrated in the bottom of
the drywells, rather than around the sides, because the native soils are porous and water percolates
downward.  EPA believes that most of the contamination has adhered to fine particles which have collected  on
top of the natural soil in the drywells.  These particles wash into the drain and clog pores of the natural
sand.  These fine particles are typically receptor sites for contaminants.  This theory is supported by the
fact that samples at incremental depths into the native soil contained very low concentrations of
contaminants.

Comment 6:  Will the soil being removed from drywells pose a danger to neighbors of the Site?

EPA Response:  Soil and sediment will be evacuated into a tank truck.  Air monitoring will be conducted on
Site during the removal operation.  If harmful levels are detected, operations will be halted and corrective
measures instituted before operations are resumed.

Comment 7:  If, in the future, the property were to be purchased for residential use, would there be any
notification that this was a Superfund site and is a record maintained for a certain period of years that
acknowledges that this was a Superfund site?

EPA Response :   After the drywell removals, EPA will propose that the Site be taken off the National
Priorities List (NPL).  The process of removing a site from the NPL includes public notice and input and the
State has to concur with the proposal.  If no contamination is detected after the removal action, EPA would
most likely not reguire that a restriction be placed in the deed. In the event that known contamination
remains, the law reguires EPA to reevaluate the Site every 5 years if contamination would    not allow for
unlimited use and unrestricted exposure.  EPA does not believe such a scenario will develop for the Anchor
Chemical site.   Also,  see response to comment 9.

Comment 8:  Reconfirming earlier discussions, if a contaminated site is cleaned up, there will be no
documentation in the deed transaction?  Does not real estate law reguire disclosure?

EPA Response:  EPA is not aware of any such reguirement; however New York State Real estate laws are not
"applicable" reguirements which EPA is reguired to consider in the site remedy selection process.  The clean
up of this Site will allow for unlimited use and unrestricted exposure.  In addition, when a Superfund site
is cleaned up and deleted from the NPL, it is no longer considered a Superfund site and no such documentation
should be reguired to protect human health.

Comment 9:  Prospective buyers of the property should be made aware of the previous nature and extent of
contamination at the site.

EPA Response:  Once the drywell removal action is complete, EPA will propose that the Site be deleted from
the National Priorities List  (NPL).  The EPA maintains a data base which contains a complete history of each
NPL Site.  The data base, which is called the Comprehensive Environmental Response, Compensation, and
Liability Information System  (CERCLIS), is available to the public.  A prospective buyer can contact EPA and
reguest information on a site from the CERCLIS database.

Comment 10:  Explain the dramatic increase in concentrations for inorganic compounds and Tentatively
Identified Compounds (TICs) between the April 1992 and November 1992 sampling events (e.g., 317 to 1440 ug/1
chromium).

EPA Response:  A high degree of variability among results for specific compounds is to be expected from the
small number of groundwater samples.  EPA recognizes presence of these contaminants and the need to address
the contamination.

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Comment 11:  Has the Hooker plant been cleaned up?

EPA Response:  There is a Record of Decision for that Site to contain the contamination and to clean up the
facility. However, there is a larger problem associated with the site:  the fact that contamination has
migrated off the property.  Since the Hooker property is adjacent to the Grumman property and the Navy
facility, there is a groundwater plume of contaminants emanating from these sites.  The New York Department
of Environmental Conservation is addressing this situation.

Comment 12:  How many Superfund  (EPA or State)  sites are there in the area?

EPA Response:  There are two Federal Superfund sites in Hicksville, New York.  There are also 9 sites under
state jurisdiction within a radius of approximately one mile of the Site.

C.    REMAINING CONCERNS

At this time, there are two issues of concern which remain. First,  the results of the soil and groundwater
samples which will  be taken to confirm the effectiveness of the drywell removals and secondly, the deletion
of the Site from the NPL.

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                 RECORD OF DECISION FACT SHEET
                         EPA REGION II

     Site:

Site name:  Anchor Chemical Superfund Site

Site location:  Town of Oyster Bay, New York

HRS score:  37.2

Listed on the NPL:  June 10, 1986


Record of Decision:

Date signed:  September 29, 1995

Selected remedy:  No Further Action


Lead:

EPA is the lead agency

Primary Contact:  Thomas Taccone; telephone number  (212) 637-4281

Secondary Contact:  Kevin Lynch, Chief, Western New York Section II;
telephone number  (212) 637-4287

Main PRPs:  K.B. Construction - tel.    (212) 940-8700
            Anchor/Lith Kem-Ko - tel.   (901) 763-6851
            Chessco industries - tel.   (516) 822-9000

Waste:

Waste type:  Chromium, lead, and volatile organic compounds

Waste origin:  Releases and spills of chemical products

Estimated waste quantity:  15 cubic yards

Contaminated medium:  Soil and sediments

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